The Ask Is Not the Bill: What Maryland Approved on LTC Rate Hikes vs. What Carriers Requested

The percentage in your rate-increase letter is an opening bid, not a bill — at least in Maryland, where the state's own 2025 approval record shows carriers getting a fraction of what they asked for. Lincoln Benefit Life requested 382% on one policy form and was approved for 15%. MassMutual asked for an average of 280% on another and got 52.1%, phased in over three years. On September 17, 2026, the Maryland Insurance Administration (MIA) held a public hearing on a new round of requests covering roughly 12,600 Maryland policyholders — and the useful question for anyone holding one of those letters is what the record says the request will become, and where it can still hurt you.

Maryland's 2025 record: the request is the ceiling, rarely the outcome

Across the 2025 decisions the MIA published, approvals landed well below requests in nearly every case, and the gap was largest where the ask was largest. The table below is taken directly from the MIA's Long-Term Care Approved Rates for 2025 page; policy-form detail is on that page for anyone who wants to match a specific form number.

Carrier	Requested	Approved	Decision date
Lincoln Benefit Life (LB-6301 / LB-7000)	382% / 360%	15% / 15%	Nov. 18, 2025
MassMutual (MM-200/300/400 series)	280% avg	52.1% (15% × 3 yrs)	June 11, 2025
MassMutual (MM500/501 series)	89.2% avg	23.7% (15%, then 7.5%)	June 11, 2025
John Hancock (LTC-02 MD, BSC-02 MD)	121.6%	15%	May 20, 2025
John Hancock (LTC-96 / LTC2000 series)	108.1%	15%	May 20, 2025
John Hancock (ICC10-LTC-11)	41.8% avg	7.5%	May 20, 2025
Transamerica (ICC13 TLC-4)	52.1% (15% × 3 yrs)	15%	July 24, 2025
Genworth (7046 MD)	51.5%	26.5% (15%, then 10%)	Mar. 11, 2025
Mutual of Omaha (ICC13-LTC13)	33.8% avg	14.6% avg	Aug. 15, 2025
Bankers Life and Casualty (GR-N520 et al.)	20.0%	Disapproved	Mar. 18, 2025

The cuts are not uniform, and the exceptions matter as much as the pattern. MetLife's group-policy request for a one-time 24.04% increase was approved at essentially the same size — 24%, but phased as 15% in year one and 7.8% in year two. Bankers Life was told no outright: the MIA noted the block's lifetime loss ratio was running close to its original pricing target. The record is consistent with regulators trimming asks that outrun the carrier's own experience data while letting well-supported ones through on a slower schedule — the seven John Hancock forms alone span approvals from 7.5% to 15% against requests from 35% to 121.6%.

This is a Maryland result, not a national one

Do not carry this pattern into another state's letter. Regulators differ in how hard they push back, and our own filing records show states approving what carriers asked for: Pennsylvania approved an average 38.7% on MassMutual's 2022 filing against a 35.8% request, and New York approved 37.5% a year for four consecutive years — both documented in the MassMutual rate-history record. Maryland's outcomes look the way they do partly because of a specific rule, and that rule is the next thing to understand.

The 15% rule is why the numbers are phased — and it has an exception

Maryland regulation bars an insurer from charging a renewal premium that exceeds by more than 15 percent any premium charged in the preceding 12 months (COMAR 31.14.01.04A(5)). That one sentence explains the shape of nearly every approval above: 52.1% is three 15% steps compounded, and 26.5% is a 15% step followed by a 10% step. The Commissioner can approve a larger single-year increase, but only on a showing that benefit utilization has run greatly in excess of what was expected (A(6)) — and none of the approvals in the table above exceeds 15% in a single year.

The same cap shows up in the 2026 requests. MedAmerica is seeking a 242% increase on policies covering 82 Marylanders, and has said no individual will see more than 15% in a year; John Hancock has asked for average increases of 27% to 142% across 19 policy types with the same 15% ceiling. Union Security has requested 101.1% and Transamerica 39.7%, according to local press coverage of the hearing. A useful tell: Union Security's 101.1% is almost exactly five 15% steps compounded (1.15⁵ = 2.011). A request that size is not a one-year event; it is a five-year schedule.

A 15% step is not a safe harbor: the nonforfeiture math

The phase-in softens each year's bill, but it does nothing to the cumulative increase — and the cumulative increase is exactly what triggers your contingent nonforfeiture rights. Under COMAR 31.14.01.13, a contingent benefit upon lapse is triggered when the insurer raises your premium to a level that is a cumulative increase over your initial annual premium equal to or exceeding a threshold that depends on your issue age, and you let the policy lapse within 120 days of the due date of the increased premium. The younger you were when you bought, the larger the cumulative increase it takes; the older, the sooner it hits.

Issue age	Maryland trigger (cumulative)	Consecutive 15% steps to reach it, from your initial premium
45–49	130%	6
55–59	90%	5
60	70%	4
65	50%	3
70	40%	3
75	30%	2
80	20%	2
85	15%	1 (exactly meets it)

Two readings follow. First, the MassMutual approval of 52.1% already exceeds the 50% trigger for someone who bought at 65 — on that increase alone, before counting any earlier increases on the same policy. Second, because the test counts every increase since your first premium, a policyholder who has already absorbed a few rounds of 10–15% increases may be one approved step away from the line, even though the newest letter looks modest. The table assumes you start at zero; your real distance depends on your premium history, which is on your old billing statements and declarations page.

Two limits keep this honest. Policies with a fixed or limited premium-paying period follow a different, lower table in the same regulation (under 65: 50%; 65–80: 30%; over 80: 10%) and carry an additional test, so check which kind you hold. And what you are offered when the trigger is met is a paid-up policy with a shortened benefit period, not your old coverage back — the mechanics are in our contingent nonforfeiture explainer.

What to do with a Maryland letter now

Treat the percentage as the start of a calculation, not the answer. In order:

1. Find your cumulative number. Divide your current annual premium by your first annual premium, subtract one. That, not this letter's percentage, is what the nonforfeiture table tests.
2. Find your issue age and policy type, then read your row in the table above (or the limited-pay table if it applies). If your cumulative figure is at or past the trigger, the 120-day lapse window after the increased premium's due date is now a live option.
3. Check whether your increase is already approved or still pending. The September 17 hearing was on requests; the hearing notice and the coverage reviewed for this piece do not say when the MIA will rule. A pending request can still shrink, as most of the 2025 table did — but a lapse decision should not rest on a number that has not been approved. The MIA's long-term care page lists decisions as they post.
4. Then pick among the actual options. The menu in the letter is the same for every carrier — see the five options in a rate-hike letter, the drop-or-keep framework, and, if your letter included a lump-sum offer, how buyout offers work. To see what a given increase does over a decade, model it in the calculator.

Carrier-specific history helps calibrate what comes next: the John Hancock, Transamerica, and Genworth records show how repeat filers behave. A 15% approval is a step, not a settlement; nothing in the 2025 record stops a carrier from filing again for the next one.

This is analysis of public regulatory records, not legal or insurance advice. Nonforfeiture elections and lapse decisions are time-limited and hard to reverse; confirm the trigger with your carrier in writing and, for a large policy, with an independent advisor or your state's insurance department before acting.